Assembly Secretariat

Waste Strategy Consultation

South East England Regional Assembly

Berkeley House

Cross Lanes




Fax: 01483 - 555250



c/o 5 Orchard Road





Dear Sir/Madam,

Consultation Draft of the Regional Waste Management Strategy from the South East England Regional Assembly (SEERA)

The Guildford Anti-Incinerator Network (GAIN) has serious concerns about Consultation Draft of the Regional Waste Management Strategy and objects to both options offered in the strategy for consultation.  The Strategy does not reflect the aspirations of many thousands of residents in the region who have expressed a strong desire for an incinerator-free approach.  Your own work has shown that such an approach is not only feasible but also the best environmental option.  We are therefore shocked that this option has not been offered in the consultation. 

We object to the following points in the Strategy:

1.      The Strategy proposes that between 11 and 27 additional “recovery” facilities, which will predominantly be incinerators, will need to be built in the region by 2010.  Residents in various parts of the South East region have repeatedly demonstrated that this technology is not acceptable to them.  Given that an incinerator-fee approach is feasible, it is very worrying that the democratic process appears to be disregarding this is aspiration.  [para. 6.3]  It seems a political decision has been taken to ignore and exclude incinerator-free options on the basis that they do not include incineration!  (The best option in your sustainability appraisal of ‘recycling and composting only’ was not pursued because it “excludes additional thermal treatment”).  

2.      Whilst the Strategy recognises that we need to “address the root causes of the growing amount of waste” [para 1.21], the policies put forward are not very convincing when it comes to delivering this vision. SEERA illustrates their lack of commitment to this vision by dismissing the concept of “zero waste production”  (ie. the long-term aim to ensure that all products are made from materials which can either be repaired, re-used or recycled). SEERA should aspire to the vision of the South West Regional Assembly who are now working towards zero waste production in their region. [policy W1-W5, para. 1.10, 5.1 - 5.18, 7.3 - 7.17]

3.      The Strategy gives a very pessimistic view of the maximum achievable levels for recycling and composting of household waste. It states that no matter what approach is used the maximum level is 50%. Even though these levels have already been achieved elsewhere the Strategy suggests that people in the South East are unique and are incapable of matching this. [policy W7 + W13, para 5.22 – 5.31, 7.18 - 7.25, 7.56]

4.      Whilst the Strategy’s vision recognises the importance of waste minimisation and more efficient management of natural resources, it is totally lacking in suggestions of how these policies will be implemented. It fails to tackle the key issues of education and awareness. [policy W1-W5]

5.      The Strategy fails to highlight the current crisis facing the incineration industry relating to the disposal of ash. Incineration reduces the weight of the waste input by up to 70% and generates ash as a by-product. According to the recent Cabinet Office report “Waste not want not”, 18% of the ash is highly toxic fly ash which must be sent to landfill sites that are licensed to accept hazardous waste. Both the Chairman and Chief Executive of the Environment Agency have recently highlighted that from July 2004 there will be no landfill space for hazardous waste in the region due to changes in landfill restrictions.  This casts serious doubt on the operational viability of incineration in the region. [policy W20, para. 5.47, 7.91-7.93]

6.      Incineration should not be classed as “energy recovery”. In February 2003 the European Court of Justice gave a judgement which supports the argument that municipal waste incineration is inherently a “disposal” operation rather than “energy recovery” (case no.  C-458/00, Luxembourg). DEFRA are currently looking into the impact of this judgement. [policy W6]

7.      SEERA have admitted that there are no accurate figures available for current waste arisings of commercial, industrial, construction and demolition waste. SEERA have relied on DEFRA’s “Waste Strategy 2000” and assumed a 3% growth figure for household waste, even though this figure has been challenged by independent experts [ref. House of Commons Environmental Audit Committee 5th Report, Session 2000/01]. Furthermore, there are no accurate figures to indicate the current amount of landfill void space. Therefore I have serious doubts about the predicted capacity figures given in the Strategy. As the chairman of the North East Region Technical Advisory Board said, “predict and provide is dead”. [para 4.9, 4.11, 4.13, 4.24]

8.      The Strategy identifies a number of possible waste management options. SEERA’s preferred option and alternative option are both based on mass-burn incineration in conjunction with recycling and composting. All other technologies are excluded from the sustainability assessment on the grounds that there is insufficient data available to illustrate their effectiveness based on the typical UK waste stream. The Government’s recent response (6 May) to the Cabinet Office “Waste not, want not” report states that the Government will “promote the development of new and viable waste management technologies”. Therefore SEERA’s selection criteria must be changed.  A further problem is that SEERA does not have sufficient information on the composition of the region’s waste stream, and has failed to commission a study to gather this information in order to establish how best to treat it. [para 6.21 – 6.33, 6.56, 6.57, 7.45 -7.47]

9.      SEERA have failed to ensure there is wide public consultation for this Strategy.  There have been no public meetings to debate the Strategy, there have been no road shows, and there has been no advertising to announce the report.  Most people are not aware that the Strategy exists.


My aspirations for waste management in the South East region are summarised below:

1.      SEERA needs to provide strong guidance to local authorities by ruling out incineration.

2.      SEERA needs to provide the leadership and plan for infrastructure to enable the people in the South East to recycle at levels beyond 50%.  As proposed in Joan Ruddock’s Municipal Waste Recycling Bill, the regional target for recycling and composting of household waste should be 50% by 2010.

3.      SEERA needs to adopt a waste minimisation target for the region. This should ultimately lead to establishing a long-term goal of working towards zero waste production. The South West Regional Assembly have already made a commitment to becoming “a minimum waste producer by 2030”.

4.      SEERA needs to promote investment in green, clean technologies for dealing with the waste that is left after an intensive waste minimisation, reuse and recycling scheme. The overall approach needs to be flexible and must rely upon sorting and cleaning the waste stream. Every household must have kerbside collection of dry recyclables, kitchen waste and un-recyclable residual waste. This approach has been tried and tested in many countries and is based on the following strategic facilities:

·       Composting facilities incorporating gas capture, with separate handling of organic garden waste (producing compost that can be sold) and of food waste (for prescribed use).  These bio-degradable materials account for much of the South East’s waste stream.

·       Sending residual waste to Mechanical Biological Treatment (MBT) facilities to reduce it, remove gases and stabilise it, then sending it to landfill for pre-treated waste (untreated landfill should be phased out).  MBT combined with incineration for processing Refuse Derived Fuel is not supported.

·       Promoting and improving facilities at Civic Amenity sites, not only to maximise reuse and recycling, but also for hazardous household waste (eg. anti-freeze, paint). As suggested in policy W12 Civic Amenity sites must be rebranded “resource recovery parks”.

5.      SEERA needs to make a commitment to waste minimisation for the commercial waste stream. As suggested in policy W13, we need separate collection of recyclable and compostable material from small and medium-sized businesses (for a fee). SEERA needs to co-ordinate local authorities in the region and make policy W13 happen. [para 7.59 - 7.60]






GAIN comments as follows on the proposed policies:


W1, 2, 3 and 4

These need strengthening.  Targets for waste reduction are needed.  These will be among the most important in the strategy if progress in tackling waste problems is to be made.  What are the mechanisms for delivering strategies?

The importance of waste avoidance should be presented more forcefully and the need to reverse waste growth trends should be an overriding priority in policy.



Welcome.  GAIN advocated a new policy to this effect in the Surrey Structure Plan.


New Policy W6a

Where is the policy on Reuse (apart from the welcome reference to construction material in W5)?  A new policy is needed to set Reuse targets as with recovery and recycling.



Your documents make it very clear (6.3) that targets can be met or exceeded using recycling and composting alone.  This should be reflected in the drafting of the policies.


Any target recovery figure used in W6 that is beyond what can be achieved by recycling and composting alone should be based on the following formula:

Recovery targets should be maximum, ambitious recycling and composting targets (in line with facilities on stream by that date) plus any reduction achievable through Mechanical and Biological Treatment to stabilise and reduce waste. 


The recommendation that Local Authorities should give priority to re-use, recycling and composting is welcome, but does not make it clear that these processes alone are sufficient to meet or exceed targets.


In order to support your aspiration of giving priority to re-use, recycling and composting, Local Authorities should ensure that their strategies and plans for meeting recovery targets are based on a compositional analysis of the waste stream for all sectors.  Basing policies on overall figures for municipal, C&I and D&C waste is not acceptable and will not achieve the objective of giving priority to reuse, recycling and composting.  For example, Surrey’s recent waste analysis has revealed a very high proportion of biodegradable waste with significant implications for the most appropriate treatment facilities.      


A sentence should be added about the importance of the stability of any residual waste resulting from any recovery process.  Concern for the stability of post recovery residual waste is as important as the proportion undergoing recovery.   


It is unacceptable that the only variable between the preferred and alternative recovery option is the amount of C&I waste recovered (excluding recycling and composting).  In practice that is likely to mean the proportion incinerated.  Variation should reflect different degrees of recycling and composting.  It is unacceptable that incineration of municipal waste by Waste Disposal Authorities is treated as a given in the consultation.  Waste contracts are being allowed to drive waste policy even though they have not been consulted upon and are undemocratic.  These contracts do include provision for variation and this consultation should allow for that.    



Various more ambitious options should be offered here. 


Local authorities should be required to ensure policies and proposals are in place to maximise recycling and composting.


The recommendations for business and industry with regard to recycling and composting are far too weak.   



This should specify recycling and composting as the priority means of achieving recovery targets.  Otherwise such a policy will simply fuel incineration proposals for C&I waste. 



The proposal to make provision for a declining amount of waste from London does not go far enough.  It is not acceptable to take net waste from London.  You appear to advocate that the region should take London’s incinerator ash in perpetuity.


Strongly object to proposed “provision of capacity for rapidly increasing … recovery.”  In this context recovery clearly means recovery that is not recycling or composting.  It could mean incineration and this is not acceptable.  The word recovery should be removed from this sentence.  A separate sentence on such recovery should be added which is much more cautious and reflects the desire of the public to pursue strategies that avoid incineration wherever possible.  Only recycling and composting are needed to achieve targets.  At present, the only other recovery technique that GAIN would support in principle is MBT in view of the role it could play in reducing and stabilising waste and in gas capture.        



We do not accept that appropriate capacity should be provided for landfill from London including incinerator ash.



Why does this policy, unlike any other, specify energy from waste as well as recovery? 

We strongly oppose the requirement in this draft policy for development plans to identify sites for energy from waste.  Quite apart from our concerns about the safety and appropriateness of incineration, this policy would prevent local authorities being able to determine the best practicable environmental option for their waste stream.  Local waste planning authorities should be able to determine that they wish to meet targets pursuing an incinerator-free approach.  Energy can be recovered from composting and MBT.



This needs strengthening.  Resource parks should be seen as playing a crucial role in educating to assist with waste reduction targets and in providing facilities for meeting reuse, as well as recycling and composting, targets.  This policy should dovetail more explicitly with W21.


Delete “…where this meets environmental, technical and operational objectives”.  Every district should have such a facility.  Community ownership of the problem and involvement in the solutions is vital.  Resource parks should be seen as a vital part of every district or borough community.



The need to collect food waste separately should be built in now rather than bolted on as EU Directives come into force.

All businesses regardless of size should fall within the requirement to sort waste.






We are very concerned by this policy, which could be used to justify incineration of material that would otherwise be composted. 

This policy should be much more cautious and be much clearer that it will not be permitted for materials that would otherwise be in the waste stream.

This policy should be in an energy, and not a waste, strategy.

It is unacceptable that this policy appears to be drafted in such as way that it assumes the biomass will be burnt rather than undergo a biological process to release its energy.  Many of our concerns about the environmental impacts of incineration would apply to the incineration of biomass grown expressly for burning.



The proposal that energy from waste should only be included in development plans “as part of an integrated approach to management to increase waste recovery rates” should be replaced with a stronger presumption against incineration   As already stated in policy W6, priority should go to reuse, recycling and composting.  It follows that other recovery should only be required where targets have not been met pursuing maximum reuse, composting and recycling.  Any recovery used in addition to these should also be the best practicable environmental option.



This should set targets for the pre-treatment and stability of landfill material as well as for cutting volumes.

Instead of encouraging collection and energy recovery from landfill gas, the strategy should be encouraging gas capture and energy recovery during composting and during MBT prior to landfill of a stabilised product.  At present polices seem to be focused on the amount of landfill at the expense of considering its nature.



The region should advocate the introduction of an incineration tax to encourage waste treatment higher up the waste hierarchy.



This policy needs to specify that waste should be stabilised and reduced not simply “treated”.



Needs to refer to wood and furniture and to batteries.  Should dovetail with policy W12.


W23 and W24

We suggest this is redrafted to reduce the likelihood that once a site is used for waste it will always be a waste site.  The best location should be decided on a case-by-case basis.  Otherwise, for example, local communities will resist a local compost plant on the basis that the site will become a waste site in perpetuity and may in future attract an incinerator application.  Just because a site was used for landfill in the past, that fact does not necessarily make it a good location for an incinerator or an MRF.  It is already hard to find waste sites without attracting avoidable long-term concerns.  



We would agree with this but fear that this policy is compromised by policy 24.


Yours sincerely


Colin Matthews